We appreciate the opportunity to provide comments on the Navy’s scoping process for the Environmental Impact Statement (EIS) for EA-18G Growler Airfield Operations at Naval Air Station (NAS) Whidbey Island. Our comments are on behalf of the more than 900 Sierra Club members on the North Olympic Peninsula directly affected by the extremely loud noise generated by the Navy’s training exercises that will be made worse by the proposed additional Growler aircraft.

Whidbey Island, where these planes are located, is a vibrant, beautiful, and historic region that has been adversely affected by the extreme aircraft noise from the Navy’s training flights. Ebey’s Landing National Historic Reserve, an over 17,000-acre national park of environmental, cultural, and historical significance has been particularly affected. The Reserve and adjoining wetlands are also an important wildlife and migratory bird habitat that is in the vicinity of an antiquated World War II landing strip, the OLF, that is used by the Navy for practice touch and go exercises. While section 106 of the National Historic Preservation Act requires the Navy to consider the effects of its operations on historic properties, potential adverse impacts on wildlife and migratory birds should also be considered in the EIS.

In addition to adversely affecting historic structures and wildlife, the Navy’s own audit found that its jet aircraft emit noise well in excess of the normal human pain threshold. Training flights have occurred at all hours of the day and night and often continue for extended periods of time. Nearby residents experience high levels of jet noise even within their shuttered houses and visitors are unable to avail themselves of state and federal recreational lands during these times.

We urge the Navy to use the “Sound Exposure Level” metric and not the “Day-Night Average Sound Level” metric in assessing the impact of noise on both humans and wildlife. The nature of the Navy’s training exercises at OLF are, by their nature, episodic and it is inappropriate to average the noise impacts over a 24-hour period. Real-time high noise events experienced with each operation should be examined rather than averages which include periods when the jets do not fly. Recent noise tests conducted by affected residents found that maximum sound levels from Growlers using the OLF were “well above the levels requiring hearing protection and are high enough to potentially result in permanent hearing loss.” The EIS should include real measuring and not computer modeling averaged over a 24-hour period.

Tourists will avoid visiting and businesses and residents will not relocate to an area that is constantly inundated with jet aircraft noise. The Navy must evaluate in the EIS the impact of jet noise on the local economies of Jefferson, Clallam, Island, and Skagit Counties. These counties, predominately rural and residential in nature, are highly dependent on recreational tourism and its associated services. In fact, fully 24% of Jefferson County’s per capita income has been attributed to the proximity of protected, natural areas like the nearby Ebey’s Landing and the numerous State parks on both sides of Admiralty Strait. The EIS must also examine how the additional Growlers and more frequent use of the OLF will adversely affect the local real estate market.

By the Navy’s own admission in its scoping materials: “Landing on an aircraft carrier is one of the most dangerous tasks a pilot can perform.” However, these training exercises, particularly those at the OLF, occur within a populated area and present unacceptable accident hazard to residents, school children, and visitors. The OLF is an antiquated World War II runway that lacks the proper clearances for safe take offs and landings and it should be closed. The EIS must look at training location alternatives to the continued use of the OLF. In 2013, the OLF wcas not used for nearly six months, during which time flight training had been safely continued elsewhere, proving that the Coupeville OLF is not an essential facility.

The EIS must also address the numerous peer-reviewed studies documenting the various health effects of aircraft noise, including permanent hearing damage, blood pressure and cardiac problems; children’s greater susceptibility to jet noise; and harm to livestock and wildlife. Studies include those by: The World Health Organization; The U.S. Department of Transportation; and The U.S. Environmental Protection Agency. The EIS should also assess the health effects of exposure to toxic jet aircraft pollution and the environmental consequences of dumping excess fuel over our waters and land.

The Sierra Club’s North Olympic Group joins with local citizens in requesting the Navy address these issues in the Environmental Impact Statement (EIS) being prepared for EA-18G Growler Airfield operations at the Naval Air Station on Whidbey Island.

Attn: Code EV21/SS
Dear Sir or Madam,
The City of Port Townsend appreciates the opportunity to provide scoping comments on the Navy’s upcoming Draft Environmental Impact Statement (DEIS) for the addition of 36 EA-18G Growler jets to the fleet of 82 existing Growlers at Naval Air Station Whidbey Island (NASWI.) Port Townsend, Washington is city of approximately 9,200 residents in Jefferson County, Washington, located across Admiralty Inlet from Naval Air Station Whidbey Island. As the legislative and policy-making body in city government, we conduct our business in full view of the public.

The Port Townsend City Council supports the need for the Navy to properly train and maintain a high state of proficiency and readiness to safeguard our nation and the men and women who serve in the Armed Forces. However, we are concerned about the way the Navy has conducted the public process, and we are worried about potential impacts of jet noise, pollution and other stressors to the health and well-being of our community and our neighbors on the Olympic Peninsula. We ask that all of these concerns to follow be addressed in the DEIS.

Our first concern is that the Navy has separated the ground, air, and sea-based activities of its proposed Electronic Warfare Testing and Training program on and around the Olympic Peninsula into different public processes that have resulted in four separate comment periods in the last five months of 2014:

1. August (Closed): The Navy’s Pacific Northwest Electronic Warfare Range Environmental Assessment, on use of roads in the Olympic National Forest;

2. September – November (Closed): The Forest Service’s decision on whether to issue a Special Use Permit for the above;

3. Closes January 9: An EIS on the Navy’s addition of 36 EA-18G Growler jets to its fleet of 82 Growlers already at NASWI;

4. Closes February 2: Changes to the EIS called “Northwest Training and Testing Draft Environmental Impact Statement/Overseas Environmental Impact Statement,” on expansion of sonar and explosive activities in the “training zone” that includes the Strait of Juan de Fuca, the waters off Indian Island, and the Olympic Coast National Marine Sanctuary, which consists of 2,408 square nautical miles off Olympic Peninsula coastline. .

The public does not view these electronic warfare testing and training activities as separate, and the Navy’s separation of them into four distinct processes have caused, and continue to cause widespread confusion and frustration among the residents of the City. We realize that the current EIS component is only about the additional 36 EA-18G Growler jets, but the air and ground-based activities in this training program are far too closely related to be considered separately. However, the National Environmental Policy Act of 1969 (NEPA) requires all federal agencies to prepare an Environmental Impact Statement whenever they undertake any significant action, and further stipulates that all activities that are functionally related must be included. We believe that these separate evaluations fail to take into account the cumulative impacts of each of the four related proposals. The lack of a cumulative impact analysis not only violates NEPA, it give the impression that the Navy is trying to “game” the system by doing a piecemeal analysis.

A 1988 Master Agreement between the Department of Defense and the US Department of Agriculture requires the Forest Service to study both the impacts of the proposed land- based training activities and the impacts of the proposed use of airspace if “directly associated with the land based training.” So the separation of ground and air-based activities into different study processes, one an EA and one an EIS, in which the public must restrict comments to narrowly defined subject areas, goes against both NEPA and the Master Agreement. We ask you to fulfill the stipulations of the Master Agreement and the requirements of NEPA, and include a thorough study of the cumulative impacts of all of the proposals related to the Electronic Warfare Range in the DEIS.

Another part of the Master Agreement authorized military use of National Forest lands only if that use is “…compatible with other uses and in conformity with applicable forest plans, provided the Department of Defense determines and substantiates that lands under its administration are unsuitable or unavailable.” NASWI is already conducting electronic warfare training at several Department of Defense bases in the Northwest that include restricted airspace and nearly half a million acres of land. Only one, the Fallon Training Range Complex, is mentioned, in a single paragraph on page 2-9 of the EA. This does not qualify as the kind of substantiation required by the Master Agreement. Also, Capt. Michael Nortier, the commanding officer at NASWI, stated as a Guest Columnist in the Whidbey Island News-Times on December 17, 2014 and in the Port Townsend Leader on December 24, 2014, “The armed services have decades of experience successfully operating similar fixed and mobile emitters at a variety of locations across the nation.” This being the case, the Navy has not shown in the DEIS how its proposal meets the condition under the Master Agreement that lands already “under [the DOD’s] administration are unsuitable or unavailable” for an electronic warfare range.

We are in possession of letters from the Boards of Supervisors in Humboldt, Marin and Mendocino Counties in California, that express deep concerns about being unaware of the Navy’s training plans along those coasts until late into the process, and later, questioning why their concerns were never addressed in the Navy’s final NEPA documents. We are worried about similar results happening here.
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Any public process must be a good faith effort. No notices about the Navy’s comment period for its Environmental Assessment (EA) were published in any newspapers that directly serve communities on the North Olympic Peninsula or West End. None of the hundreds of citizen comments that were given at public informational meetings (which occurred only because of the insistence of Congressman Derek Kilmer) were ever recorded for the official record. In its public outreach materials for the Olympic Peninsula, the Navy shows the 15 locations proposed for the use of the emitters using a map that erases Lake Quinault, all major rivers, and all boundaries between the Olympic National Forest and Olympic National Park. If helping the public understand exactly where the emitters are to be located was the purpose of the map, then why was so much important detail omitted?

We question the transparency of the Navy’s public process, and in particular, how it justifies the fact that after a comment period on its EA that was half the 30-day minimum length recommended by NEPA, it issued immediately after and continues to stand by, a Finding of No Significant Impact (FONSI) that includes this statement: “The Navy received no comments from individuals, elected officials, government organizations, or Native American Tribes in response to the Draft EA.” Once the public became aware of the Navy’s plans, more than 3,000 comments poured in during the October-November comment period on whether the Forest Service should issue a Special Use Permit for use of its roads, thus refuting any previous implications that public concern is lacking. With these problems in mind, we would like to see the FONSI revisited and an EIS process initiated to combine all of the proposed activities, and to address concerns that have been raised about potential impacts to the health, economic and ecological values of all communities and public lands that will be affected.

Our second major concern is with noise. Over the past several years there has been a marked increase in jet noise around the Olympic Peninsula. Flights at OLF-Coupeville increased from 3,200 in 2010 to 13,300 in 2012. The number of flights is likely to increase given the relocation of the nation’s entire Growler fleet to NASWI, and the fact that the Navy has embarked on a contract to train foreign pilots at NASWI. Although the Navy is authorized to fly at 6000 feet above mean sea level, its pilots are allowed to fly as low as 1200 feet above ground level over some parts of the Olympic Military Operating Area (MOA,) which occupies the airspace over the Olympic National Forest and Olympic National Park. Additionally, Growlers taking off and landing at NASWI are more likely to fly at lower altitudes over Port Townsend, thus creating more noise.
The Navy uses the “Day-Night Average Sound Level” calculation to assess noise levels, but uses a jet engine placed on a test platform and a computer modeled calculation rather than an actual jet. Using a similar method to what the FAA uses at commercial airports, the Navy averages the noise levels over 365 days that include quiet periods in order to calculate noise levels. Growlers can produce enough noise to cause hearing loss. They are capable of speeds of 1400 mph, and unlike the subsonic Prowlers they are replacing, which can fly at 600 mph, Growlers are capable of producing sonic booms, which have been described at public meetings by residents of communities on the West End. Navy statistics for older jets say they can produce 113 decibels at an altitude of 1000 feet, which is above the human pain threshold. No accurate sound measurements for Growlers have been provided by the Navy to other agencies or to the public.
Since the fuselage, external instruments and weapons attachments on a jet create additional noise to that of the engine, especially at takeoff and landing, and since afterburners are frequently used but have not been included in any noise level calculations, we ask that this be rectified with more accurate noise measurements that use a more realistic means of feedback. Computer modeling that averages noise over a year of quiet periods reflects neither the aforementioned aspects nor the episodically extreme nature of Growler jet noise. Federal and state agencies rely on the Navy’s noise data to assess potential impacts to threatened and endangered species. If such measurements do not reflect the realities of Growler jet noise, documentation of their application in assessing impacts may be invalid.

There has been no discussion or documentation from the Navy on impacts to property values or tourism-based economies from jet noise. Port Townsend is an historic Victorian Seaport. Much of its residents’ livelihoods are closely tied to the tourism industry, and increased training flights, especially at night may have an adverse effect on our tourist economy. We ask that these analyses be included in the DEIS. We are aware of the devastating impact on from jet noise on the real estate market at North Whidbey Island, and have similar concerns for Port Townsend.

There are numerous peer-reviewed scientific studies, including reports by the Environmental Protection Agency, the World Health Organization, and the US Department of Transportation, on the health effects of aircraft noise and pollution. The DEIS must address these issues using a thorough analysis of existing scientific literature.

The EA is inconsistent in providing assurance that electronic attack weapons will not be used as part of the training exercises. The Olympic Peninsula is no longer lightly populated as it once was when the Military Operating Areas were established, and places like Olympic National Park receive more than 3 million visitors per year who spend hundreds of millions of dollars in surrounding communities. If visitors become concerned that they may be entering a warfare training range where weapons such as lasers or high- powered microwaves or EMPs are being used overhead, tourism and the revenues from it could drop off drastically. At several public meetings the Navy has stated that no electronic attack weapons will be fired, yet in Section 4.2.1.3 of the EA it says the mission is to provide “combat-ready Tactical Electronic Attack squadrons which are fully trained.” We ask that the DEIS answer the question of how, when and where the use of electronic attack weapons will occur.

The Pacific Northwest Electronic Warfare Range covers more than just the Olympic National Park and Olympic National Forest; it also includes DNR, Tribal and private lands in western Clallam, Jefferson and Grays Harbor Counties, as well as off-lying waters that include the Olympic National Marine Sanctuary plus the Strait of Juan deFuca and Puget Sound. Anything less than a full analysis of all impacts from the Navy’s
Electronic Warfare Testing and Training program in all of these areas would be less than adequate.
We write this letter after receiving many comments from our constituents. On behalf of the City of Port Townsend, we ask that ALL impacts of the Navy’s Electronic Warfare Testing and Training program be discussed in one comprehensive document, and that the stipulations of the 1988 Master Agreement be followed.